All American Semiconductor, Inc. v. Hynix Semiconductor, Inc. et al

Filing 389

STIPULATION AND ORDER TO CANCEL CASE MANAGEMENT CONFERENCE re 388 Stipulation filed by All American Semiconductor, Inc. Signed by Judge Phyllis J. Hamilton on 12/12/11. (nah, COURT STAFF) (Filed on 12/12/2011)

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PETER W. JAMES, Bar No. 041410
BAKER & HOSTETLER LLP
12100 Wilshire Boulevard, 15th Floor
Los Angeles, California 90025-7120
Telephone:
310.820.8800
Facsimile:
310.820.8859
Email:
[e-mail]
Attorneys for Plaintiff
ALL AMERICAN SEMICONDUCTOR, INC.

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ROBERT W. TURKEN (pro hac vice)
SCOTT N. WAGNER (pro hac vice)
BILZIN SUMBERG BAENA PRICE
& AXELROD LLP
1450 Brickell Avenue
Suite 2300
Miami, FL 33131
Telephone:
305.374.7580
Facsimile:
305.374.7593
Email:
[e-mail]
[e-mail]

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Attorneys for Plaintiff
ALL AMERICAN SEMICONDUCTOR, INC.

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[Additional counsel listed on signature pages]

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UNITED STATES DISTRICT COURT
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FOR THE NORTHERN DISTRICT OF CALIFORNIA
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OAKLAND DIVISION
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ALL AMERICAN SEMICONDUCTOR, INC.,

CASE NO. 07-cv-1200 (PJH)

Plaintiff,
v.
HYNIX SEMICONDUCTOR, INC., et al.

JOINT STIPULATION AND [PROPOSED]
ORDER TO CANCEL CASE
MANAGEMENT CONFERENCE

Defendants.

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JOINT STIPULATION AND [PROPOSED] ORDER TO CANCEL CASE MANAGEMENT CONFERENCE

Plaintiff All American Semiconductor, Inc. and Defendants Nanya Technology Corp. and

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Nanya Technology Corp. USA (collectively, “Nanya”) hereby stipulate as follows:
WHEREAS, the remaining parties in this litigation have reached a settlement in principle

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resolving this case;
WHEREAS, Plaintiff and Nanya expect to file a stipulation of dismissal as to Nanya within

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the next 45 days; and

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WHEREAS, due to the forthcoming dismissal of this action as to Nanya, the Case

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Management Conference currently scheduled for Thursday, December 15, 2011 at 2:00 p.m. is no

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longer necessary;
IT IS HEREBY STIPULATED by and between Plaintiff and Nanya that the Court should

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cancel the Case Management Conference currently scheduled for December 15, 2011 at 2:00 p.m.;

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and

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IT IS HEREBY FURTHER STIPULATED by and between Plaintiff and Nanya that should a

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stipulation of dismissal of this action as to Nanya not be filed within the next 45 days, Plaintiff and

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Nanya shall so advise the Court and provide an explanation as to the status of settlement negotiations,

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and shall make any additional requests of the Court as appropriate at that time.

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IT IS SO STIPULATED, AGREED, AND RESPECTFULLY REQUESTED.

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DATED: December 7, 2011

BILZIN SUMBERG BAENA PRICE & AXELROD
LLP
ROBERT W. TURKEN
SCOTT N. WAGNER

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By:

/s/ Scott N. Wagner
Scott N. Wagner

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Attorneys for Plaintiff
ALL AMERICAN SEMICONDUCTOR, INC.

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JOINT STIPULATION AND [PROPOSED] ORDER TO CANCEL CASE MANAGEMENT CONFERENCE

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DATED: December 7, 2011

ORRICK HARRINGTON & SUTCLIFFE LLP
HOWARD ULLMAN

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By:

/s/ Howard M. Ullman
Howard M. Ullman

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Attorneys for Defendants
NANYA TECHNOLOGY CORPORATION USA AND
NANYA TECHNOLOGY CORPORATION

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JOINT STIPULATION AND [PROPOSED] ORDER TO CANCEL CASE MANAGEMENT CONFERENCE

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ATTESTATION OF FILING
Pursuant to General Order 45.X.B, I hereby attest that I have obtained concurrence in
the filing of this document from the parties listed above.

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/s/ Scott N. Wagner
Scott N. Wagner

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JOINT STIPULATION AND [PROPOSED] ORDER TO CANCEL CASE MANAGEMENT CONFERENCE

[PROPOSED] ORDER

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IT IS SO ORDERED.

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December 12
Date: ____________________, 2011

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A

H

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Hamilto

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Judge P

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hyllis J.

NO

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FO

UNIT
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___________________________________________
United IT IS SO ORDERED Judge
States District
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S DISTRICT
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JOINT STIPULATION AND [PROPOSED] ORDER TO CANCEL CASE MANAGEMENT CONFERENCE

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CERTIFICATE OF SERVICE

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I HEREBY CERTIFY that on December 7, 2011 I electronically filed the foregoing

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Stipulation via CMF/ECF on all interested parties registered for e-filing in this case. I also certify

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that a true and correct copy of the foregoing is being served by U.S. Mail on the following parties:

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PLEASE SEE ATTACHED SERVICE LIST
I declare under penalty of perjury under the laws of the United States of America that the

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foregoing is true and correct.
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/s/ Scott N. Wagner
Scott N. Wagner

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JOINT STIPULATION AND [PROPOSED] ORDER TO CANCEL CASE MANAGEMENT CONFERENCE

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SERVICE LIST
Howard M. Ullman, Esq.
Orrick, Herrington & Sutcliffe LLP
The Orrick Building
405 Howard Street
San Francisco, CA 94105
Telephone:
[phone]/5652
Facsimile:
[phone]

Attorneys for Defendants
Nanya Technology Corporation USA and
Nanya Technology Corporation

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JOINT STIPULATION AND [PROPOSED] ORDER TO CANCEL CASE MANAGEMENT CONFERENCE